I am to inform you that as the suggested amendments are only such as would
appear to be desirable in order to make the intention of the regulations
clear or to give formal sanction to existing practices in the interests of
safe navigation, and as they would only affect comparatively few vessels of
special types, His Majesty’s Government in the United Kingdom would propose
that they should be embodied in the Revised Regulations. It is hoped that
the United States Government will feel able to concur in the amendments
proposed.
The majority of the Governments concerned have already, either directly or
indirectly, signified their acceptance of the Revised Regulations and
certain Governments have, moreover, intimated their desire to be informed of
the date of operation proposed by His Majesty’s Government in sufficient
time to enable the adoption of the
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Revised Regulations to be announced at least six months before they are to
become operative. I am to inform you that in the opinion of His Majesty’s
Government in the United Kingdom the 1st January 1933 might well be fixed as
the date for the simultaneous adoption of the Revised Regulations, including
the additional amendments suggested in the enclosed memorandum.
His Majesty’s Government in the United Kingdom hope that the proposed date
for bringing the Revised Regulations into force will be agreeable to the
United States Government and they would be glad to receive the views of the
United States Government on this matter at latest by the 1st March 1932.
[Enclosure]
International Regulations for Preventing Collisions at
Sea
Suggested Amendments to the Revised Text Proposed
by the International Conference on Safety of Life at Sea,
1929
Naval Vessels.
Article 2.—Proposed by the Government of the United Kingdom of Great
Britain and Northern Ireland, that the following addition should be made
to the note at the end of this article:—
“and naval vessels in which it is not practicable to carry the
second white light referred to in sub-division (b) of this article shall not be required
to carry it.”
There was considerable discussion on the Navigation Committee of the
International Conference on Safety of Life at Sea, 1929, as to whether
certain classes of naval vessels could comply with the new requirement
in article 2 (b) of the revised Regulations that
vessels of 150 feet or more in length should carry a second steaming
light. One delegation was definitely of opinion that the practical
difficulties in the way of compliance were such that naval vessels
should be exempted entirely from the requirement but this opinion was
not pressed, and, with a view to meeting these and other difficulties
affecting naval vessels, it was agreed to add the note at the end of
article 2, which permits, in the case of naval vessels of special
construction, a departure from the requirements of the article as to the
position of lights or their range of visibility. The entire omission of
the second steaming light would, however, not be in accordance with the
note.
Exhaustive trials, which have since been made by His Majesty’s Government
in the United Kingdom, have shown that in certain classes of naval
vessels, particularly submarines and the older
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destroyers, the carrying of the second steaming
light would endanger the safe navigation of the vessels or would involve
very extensive and unduly costly alterations to them. It is believed
that the naval authorities of certain other countries also take the view
that such vessels could not reasonably be expected to comply with
article 2 (b) of the revised Regulations. The
amendment now proposed will obviate any difficulty in this respect.
Article 10.—Proposed by the Netherlands Government that to this article
should be added a note similar to that proposed by the International
Conference on Safety of Life at Sea, 1929, for inclusion at the end of
article 2 of the revised Regulations, namely:—
“In naval vessels of special construction in which it is not
possible to comply with the provisions of this article as to the
position of lights or their range of visibility, those
provisions shall be followed as closely as circumstances will
permit.”
The Netherlands Government point out that, as the revised article now
stands, submarines have to comply with the general requirement that a
vessel when under way shall carry a white light at her stern. While it
is possible for a submarine to carry the prescribed light, under certain
circumstances a light affixed to the very low after-part would be
submerged, and for this reason the light is often carried on the
turret.
When the matter was under consideration at the International Conference
on Safety of Life at Sea, 1929, the original intention was that all the
regulations relating to navigation lights should be included in one
article (article 2), and in that case the special exception now embodied
in article 2 as regards steaming and side lights of naval vessels would
have applied also to stern lights. Finally however, in order to avoid
renumbering all the articles following the existing article 10, it was
decided to retain the original arrangement of the articles, but the
Conference omitted to include in article 10 the intended exception in
favor of naval vessels. The amendment now proposed will rectify this
omission.
Fishing Vessels.
Article 9 (b) and (c).—Proposed by the Government of Japan, that the words “and
Korea” should be omitted from the phrase “in the seas bordering the
coasts of Japan and Korea,” which appears in paragraph (b) and again in paragraph (c) of article 9.
In explanation of this proposal the Japanese Government state that the
phrase is intended to cover the seas washing all the shores of Japan,
and they think that the retention of the words “and Korea” may give rise
to some doubt as to whether its application is
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not confined to the seas bordering the coasts of
Japan proper and Korea to the exclusion of other parts of the Japanese
Empire, such as Formosa and Saghalien.
It will be noted that the proviso of which the phrase in question forms
part, only applies to sailing fishing vessels of less than 20 tons gross
tonnage.
Pilot Vessels.
Article 15.—Proposed by the Belgian Government that the footnote to this
article should be amended so as to commence:—
“Dutch and Belgian steam pilot vessels . . . .”
The Belgian Government explain that they consider it would be useful to
introduce for use by Belgian steam pilot boats the same special fog
signal as that used by Dutch steam pilot boats which are engaged in the
same waters.
The footnote appears to be intended merely to give information as to the
distinctive manner in which the steam pilot vessels in question comply
with the requirements of article 15 regarding sound signals for steam
vessels under way in fog, &c., and no departure from or alteration
in the Collision Regulations themselves is involved.
Position of Forward Anchor Light.
Article 11.—Proposed by the Netherlands Government that the words “and
not exceeding 40” should be omitted from the second paragraph of this
article, which requires the forward anchor light of a vessel of 150 feet
or upwards in length to be carried at a height not less than 20, and not
exceeding 40, feet above the hull. In support of the amendment, it is
stated that, on occasions, a height of 40 feet above the hull is
insufficient, presumably because, on vessels with extensive
superstructures, the latter would obstruct an anchor light placed 40
feet above the hull and would prevent it from showing all round the
horizon.
It is understood that, in practice, the anchor light on vessels having
high superstructures is placed at a height of more than 40 feet above
the hull, if this is necessary to secure its visibility all round the
horizon. The amendment now proposed thus harmonises with existing
practice.
Board of Trade, November 1931.
